Reshaping the Endangered Species Act: A Holistic Approach Needed? - Lynn Scarlett
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Date
Issue Brief #
ISSUE BRIEF
Reshaping the Endangered Species
Act: A Holistic Approach Needed?
Lynn Scarlett
June 2010
Issue Brief 10‐15
Resources for the Future
Resources for the Future is an independent, nonpartisan think
tank that, through its social science research, enables
policymakers and stakeholders to make better, more informed
decisions about energy, environmental, natural resource, and
public health issues. Headquartered in Washington, DC, its
research scope comprises programs in nations around the
world.
2 SCARLETT | RESOURCES FOR THE FUTUREReshaping the Endangered Species Act:
A Holistic Approach Needed?
Lynn Scarlett1
Over a half century ago, noted conservationist Aldo Leopold heralded the importance of
landowner stewardship (Leopold 1949). He applauded wildlife preserves, reserves, and parks but
perceived that nature needed nurturing in backyards, communities, and on working landscapes.
Today, the nation still struggles to fulfill Leopold’s vision.
Nowhere is this struggle more evident than in the Endangered Species Act (ESA). In 1973, the
Congress, with overwhelming approval, enacted the ESA to prevent the extinction of imperiled
plants and animals. The act sets forth procedures to identify, list and protect threatened and
endangered species. These protections include measures to restrict activities that would “take”
(harm or harass) listed species. Because many endangered and threatened species live at least in
part on privately owned lands, engaging landowners in their protection is critical to the act’s
success. Yet many critics argued that the act had the opposite effect, discouraging private
landowner stewardship. Indeed, after its enactment, the ESA rapidly became one of America’s
most controversial laws, generating hundreds of legal challenges by government authorities,
conservationists, landowners, and industry.
Three policy issues shape modern challenges to fulfilling the purposes of the ESA:
z Saving imperiled plants and animals on both public and private lands remains a daunting
mandate. However, the nature of that task has evolved from one of strengthening
landowner incentives for species protection toward one of coordinating the stewardship
actions of multiple land managers across jurisdictional and ownership boundaries.
………………………………….
1 Lynn Scarlett is a visiting scholar at RFF. She served as the Interior Department’s Assistant Secretary for Policy, Management and Budget
from 2001 to 2005 and the Deputy Secretary from 2005 to 2009.
1 SCARLETT | RESOURCES FOR THE FUTUREz The species‐by‐species focus of the act is inconsistent with natural processes. Nature as we
know it is characterized by interconnections, synergies, and interdependence. Species
function interdependently across landscapes and ecosystems, yet the act is structured to
focus on individual species, not their interconnected relationships within a functioning
ecosystem.
z Effectively integrating science with management expertise and experience in the field is
imperative in species management and recovery planning. These efforts cannot be left solely
to scientists; a spectrum of players must be engaged, including farmers, ranchers, timber
managers, fishermen, and others on public and private lands and waters.
Evaluating the Success of ESA
ESA observers typically measure success by tallying the number of species listed and delisted
under the act, yet this simple metric conveys an incomplete picture of ESA’s far‐reaching effects.
The act has significantly influenced public and private decision making, far more than any
legislation in the era prior to enactment (Yaffee 2006). The act helped trigger extensive data
gathering and analyses (Scott et al. 2006) and has motivated numerous large, landscape‐scale
conservation initiatives—for example, the Platte River Recovery Implementation Plan, the Upper
Colorado River restoration, and the Missouri River restoration. Many of these efforts link public
and private actions.
Illustrative of these many efforts, the Platte River Recovery Implementation Program was initiated
in 2007 after a decade of negotiations.2 The cooperative agreement and resulting program
agreement, signed by the secretary of the interior and the governors of Nebraska, Wyoming, and
Colorado, responded to a history of concerns and litigation over endangered species and water
uses along the river.
The Platte River program implements certain aspects of the Fish and Wildlife Service’s (FWS)
recovery plan for four listed species—the whooping crane, least tern, pallid sturgeon, and piping
plover—along the river, in the context of sustainable and multiple water uses in a predominantly
agricultural region. The program includes provisions to: (1) recover more historical patterns of
stream flow during relevant times of the year through retiming and water conservation and
supply projects, and (2) enhance, restore, and protect habitats for the four listed species. A key
component is an adaptive management plan, which provides a systematic process to test
hypotheses about management strategies that will most effectively achieve program objectives.
Improvements in the status of the four species and associated river form and function will guide
decisions about the most appropriate management strategies.
………………………………….
2 See www.dnr.state.ne.us/PRRIP/docs/PRRIP_ProgramDoc.html (Accessed May 30, 2010).
2 SCARLETT | RESOURCES FOR THE FUTUREThat most listed species remain designated as threatened or endangered is a consequence of
many factors. The act’s early failure to set forth a context that motivated private stewardship has
been one issue. But getting those incentives right through such tools as safe harbor agreements
and recovery credits is not likely get vast numbers of species off ESA lists. The effects of a
changing climate, land fragmentation, persistent environmental contaminants, and water scarcity
all continue to threaten species in ways that transcend decisionmaking incentives within the ESA’s
provisions. Moreover, with listings often occurring well after some species have experienced
serious population declines and habitat losses, their prospects for recovery, once listed, are often
limited.
The Ongoing Saga of Private Incentives
Key to fulfilling the ESA is public and private land stewardship. More than 80 percent of species
listed as endangered or threatened are found, at least in part, on private lands, and some one‐
third may be found only on private lands (Government Accountability Office 1994). Species
conservation must be a matter for both public and private action.
Many ESA observers have lamented the limited successes in species conservation if the metric is
removal of species from the threatened and endangered lists (Goble et al. 2006). Under the act,
the nation has put many species in the “emergency room,” to borrow a much‐used metaphor. But
guardians of species under the act have been less adept at making them well—that is, bringing
populations back to levels of recovery (Goble et al. 2006).
The nation can do better, and private lands are important for future success. Through the 1990s, a
growing concern surfaced about the ESA’s effects on landowner incentives to engage in species
conservation. Critics have accused the act’s regulatory constructs of reinforcing a landowner
“fortress mentality” that blocked access to information about species on private lands (Polasky
and Doremus 1998). They have criticized the act’s potential to discourage species protection on
private lands as landowners feared the regulatory implications of supporting at‐risk species on
their lands.
These were central challenges in the first three decades after passage of the act. To some extent,
they remain challenges. Nonetheless, over the past 15 years, many innovations have softened
these disincentives. The ESA toolkit now includes safe harbor agreements, a “no surprises” rule,
candidate conservation agreements with assurances, and habitat conservation planning with
incidental‐take permits. These agreements and rules establish restrictions on land use to protect
listed and other at‐risk species but provide landowners with assurances that no additional
restrictions will be required in the future. All these tools partly remedy the problem that
landowners have been reluctant to undertake conservation measures for fear that the presence
of endangered species on their lands would invoke onerous land use restrictions.
3 SCARLETT | RESOURCES FOR THE FUTURETwo additional tools—conservation banking and recovery credits—go beyond simply removing
disincentives and instead establish some value in species conservation.
California pioneered use of conservation banks by issuing a policy in 1995 that allowed the
conservation of land parcels, managed in perpetuity through easement provisions to benefit at‐
risk species. These permanently protected lands, which can be publicly or privately owned and
managed, contain specific habitat features that benefit endangered species. “Overall, the practice
of conservation banking refers to the process of setting up species credits via a banking
agreement and the ‘trading’ (i.e., using or selling) of those credits” (Fox and Nino‐Murcia 2005).
The holders of easements are granted credits within a defined area based on the bank’s species
and habitat values. Bank owners use or sell the credits to mitigate impacts to species protected
under federal or state law. In 2003, the FWS adopted federal guidance on conservation banking
(FWS 2003).
Though no formal database tracks conservation banking, a 2005 report identified 76 conservation
banks, of which some 35 were approved by the U.S. Fish and Wildlife Service (FWS, 2005, 1001).
The 2005 report indicated that 91 percent of these banks were financially motivated, with the
majority of the for‐profit banks breaking even or making money. In 2007, an informal tally
undertaken at the Department of the Interior identified 78 banks that protected habitat to
provide mitigation offsets for federally listed species (Maillett and Simon 2007). More recently, as
of January 2009, The National Mitigation Banking Association reports that over 90 conservation
banks now protect some 90,000 acres of habitat but detailed analysis of these banks is not
available.
Recovery credits, like conservation banks, provide federal agencies a tool to implement actions on
private lands to protect threatened and endangered species by offsetting adverse impacts
elsewhere on federal lands. Recovery credits allow federal agencies to offset the impacts of their
actions on threatened and endangered species on federal lands through conservation actions on
non‐federal lands if these actions result in net conservation benefits for the affected species. The
Department of Defense first used them to offset impacts on the golden‐cheeked warbler at Fort
Hood by contracting through a reverse auction with private landowners for benefits provided
from wildlife management plans (Robertson and Rinker 2010).
Both of these conservation tools provide some motivation for private landowner stewardship and
offer opportunities to cluster benefits and coordinate private stewardship on multiple properties,
providing a more holistic or landscape‐scale conservation setting. But they are also far from
perfect. The imperfections cluster into several categories:
z sometimes burdensome and time‐consuming procedures (the average time to establish a
conservation bank, for example, is more than two years) (Fox and Nino‐Murcia 2005);
4 SCARLETT | RESOURCES FOR THE FUTUREz performance requirements built on sometimes inadequate information (Robertson and
Rinker 2010, 22);
z an emphasis on management prescriptions rather than on performance measured as species
outcomes; and
z limited incentives in the context of private use of public lands for ranching and other
purposes.
In addition, conservation banking and many other ESA agreements require permanent
conservation protections, which some critics believe provide disincentives for participation and
are ill‐suited to dynamic environmental conditions. Yet these requirements are not inconsistent
with adaptive management. In the context of the ESA, conservation banks are intended to sustain
conditions that benefit targeted species. Through monitoring, management practices within a
conservation bank can be adjusted to improve species benefits in an adaptive context. In the case
of catastrophic or dramatic landscape changes—for example, the consequences of floods or fire—
a better remedy than time limitations on conservation agreements is some sort of insurance
mechanism or reserve pool of conservation and recovery credits. Recovery credits, in contrast to
conservation banks, often use a term‐limited contract, with many contracts lasting 7 to more than
20 years.
Importance of Public‐Private Partnerships
In considering incentives, a broader framework is useful for thinking about private stewardship,
conservation, and species protection. Across the nation, new formal and informal institutions are
emerging, along with new types of cooperative conservation and collaborative problem solving.
These efforts are relevant to conservation in general and to the ESA context in particular, for
several reasons. First, nature knows no boundaries. Problems such as vegetative fuel buildup in
forests, water quality problems in waterways, and the spread of invasive species need
collaborative public and private actions across jurisdictions and land ownership boundaries.
Second, as Aldo Leopold noted, the nation cannot rely only on “reserves” alone—whether parks
or conservation banks—to achieve conservation goals. Species protection requires conservation
on working landscapes and across boundaries. This requisite suggests the need for
decisionmaking contexts that facilitate bargaining, negotiating, and collaboration to accompany
conservation incentives.
Such contexts do not derail property rights, as some argue. Instead, they affirm such rights but
recognize the importance of governance mechanisms to coordinate action where problems
5 SCARLETT | RESOURCES FOR THE FUTUREtranscend landowner and jurisdictional boundaries, many rights intersect, and public resources
and wildlife are involved.
An examination of the Upper Colorado River management initiative that involves many agencies
and participants offers useful insights on collaboration and the ESA (Yaffee 2006). The
management regime unfolds on an ecosystem scale, with a multispecies focus in which
conservation actions take place on working landscapes in a context of technical and financial
incentives to enhance participation. These features set the foundations for twenty‐first century
environmental performance, the recovery of species, and enhancement of habitat health.
Some of the best prospects for stimulating private stewardship and cross‐boundary coordination
lie alongside rather than within the ESA context. Programs such as the Partners for Fish and
Wildlife Program, Joint Ventures, Coastal Program, Farm Bill conservation grants, and other
similar programs inspire landowner stewardship through technical and financial assistance and
rewards. These conservation programs increasingly operate on a landscape scale, bringing
together multiple landowners to coordinate conservation activities within watersheds and broad
ecosystems. Many of these programs function through competitive awards with a focus on
performance. Yet some of the best opportunities to enhance species protection lie in
strengthening the performance provisions of these programs to include species protections. Tens
of thousands of landowners participating in these programs are engaged in land stewardship and
land health ventures.
Other policies could further strengthen participation in these non‐ESA programs. Tax code
changes through which conservation grants are not deemed income would be helpful. Many Farm
Bill conservation grant programs provide a precedent for such tax treatment. There is also the
matter of funding. Current funding is inadequate for FWS employees to do all that is required of
them—and all that is needed to enhance species protection. And an endless weight of lawsuits,
often centered on process, deflects focus away from critical priorities. Citizen watchdogs help
provide accountability through these lawsuits, but ESA decisionmakers need to ask whether the
current approach strikes the right balance between assuring that citizens can hold their
government accountable and enabling agencies, using their expertise, to set priorities and focus
their actions on achieving outcomes.
The ESA toolkit, with safe harbor agreements, the “no surprises” rule, conservation banks, and
recovery credits, seems to have significantly softened landowner disincentives to protect species.
Extending safe harbor agreements to actions within some of these non‐ESA conservation
programs could potentially attract additional participants.
6 SCARLETT | RESOURCES FOR THE FUTUREBeyond Incentives: The Multispecies Conundrum
Though ESA implementation could benefit from continuing improvements to tools that provide
landowner stewardship incentives, the act is much better equipped to address the incentive issue
than it was in the 1990s. Yet administrators are still grappling with a challenge just a central to the
ESA’s success: how to pivot from a species‐by‐species approach to a multispecies one. A related
challenge is how to pivot to landscape‐scale efforts.3
In 2008, the FWS developed a proposed rule to protect 48 Kauai, Hawaii, species as endangered,
the first‐ever listing that used an ecosystem‐based approach. Published as a final rule in April
2010, the action also designated critical habitat for 47 of the listed species. The rule was path
breaking for two reasons. First, it grouped species by ecosystem type and identified factors in
those ecosystems that created shared threats to multiple species. Second, rather than identifying
small, individual patches of critical habitat occupied by each species, the rule used a more holistic
process to designate particular ecosystem types and areas, for a total of 26,582 acres, deemed
important to the protection and recovery of the listed species.
In the preamble to the rule, the FWS highlights the ecosystem‐based approach, noting, “On the
island of Kauai, as on most of the Hawaiian Islands, native species that occur in the same habitat
types (ecosystems) depend on many of the same biological features and on the successful
functioning of that ecosystem to survive. We have therefore organized the species addressed in
this final rule by common ecosystem” (FWS 2010).
In taking this pioneering step to use an ecosystem approach, the FWS affirms what many critics
have long observed. The FWS notes that many species share ecosystems and, thus, face common
threats that “require similar management actions to reduce or eliminate those threats.”
Moreover, the FWS states that “effective management of these threat factors often requires
implementation of conservation actions at the ecosystem scale to enhance or restore critical
ecological processes and provide for long‐term viability of those species in their native
environment” (FWS 2010).
In other words, though the FWS deemed this approach efficient and less redundant than a
species‐by‐species narrative, a central motivation for using an ecosystem approach was “to more
effectively focus conservation management efforts on the common threats that occur across
these ecosystems, restore ecosystem function for the recovery of each species, and provide
conservation benefits for associated native species.”(FWS 2010)
………………………………….
3 While several cases of multispecies listing have occurred, such listings are unusual, in part because of difficulties presented by the
provisions of the ESA for taking such an approach.
7 SCARLETT | RESOURCES FOR THE FUTUREThough the FWS succeeded under the existing act in crafting an ecosystem‐based rule, language
in the rule’s preamble includes a subtle but significant additional statement that hints at the
difficulty the act may present difficulties for broadly using this multispecies, ecosystem‐based
approach. Specifically, the FWS states, “Although the listing determination for each species is
analyzed separately, we have organized the specific analysis for each species within the context of
the broader ecosystem in which it occurs to avoid redundancy.” The preamble also discusses the
critical habitat designation, stating: “although critical habitat is identified for each species
individually, we have found that the conservation of each depends, at least in part, on the
successful functioning of the commonly shared ecosystem.”
This language is carefully chosen, because the act establishes requirements for listing individual
species and designating habitat for each listed species. The act’s focus is on individual species
rather than groups of species within a shared habitat (FWS 2010).In addition, the law includes five
different categories of threats to assess the status of a species. Habitat degradation (ecosystem
threat) is just one of the five threat categories.
The FWS announced that it plans to undertake ecosystem‐based, multispecies analyses for all of
the endemic Hawaiian species that are candidates for potential listing under the ESA. They
anticipate one rule for each island of Oahu, Hawaii, and Maui Nui (which includes four islands).
How well this approach, without some modifications in laws or regulations, will be applicable in
other (non‐island) circumstances remains untested.
Beyond the process of listing species and designating critical habitat, other features in the law’s
implementation present management challenges for using an ecosystem framework. Section 9 of
the ESA makes it illegal to “take” an endangered species of fish or wildlife. The definition of “take”
is to “harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or to attempt to
engage in any such conduct.” At an ecosystem scale, with multiple listed species, actions that
benefit one species may harm another. The ESA does not envision or provide a framework for
addressing these sorts of trade‐offs.
Precisely this sort of tension now complicates Everglades restoration and efforts in the California
Bay‐Delta region to protect both Delta smelt and salmon. In the Everglades, enhancing water
flows across the southern Everglades, a central goal of restoration, is critical to the sustenance of
the endangered snail kite and many other Everglades species. However, the century‐old alteration
of the Everglades landscape has altered species distribution patterns. For example, the Cape Sable
seaside sparrow now uses some inland habitat for nesting. Rewetting these areas could adversely
affect the sparrow. As a result, managers face a dilemma—how to achieve restoration with its
concomitant multispecies benefits while not “taking” species like the Cape Sable seaside sparrow.
8 SCARLETT | RESOURCES FOR THE FUTUREIn the Bay Delta, the water management regime deemed necessary for the Delta smelt, if not
carefully calibrated, may actually be detrimental to salmon. Federal managers sought court
approval to combine the analyses of the two species, but approval was not forthcoming.
Managers thus prepared biological opinions and corresponding management regimes for each
species individually, heightening the prospects of conflicting requirements for the two species. It
is possible to transcend these tensions through careful coordination among the several federal
and state agencies with regulatory and management responsibilities for the Delta smelt and
salmon, but the act does not facilitate such coordination.
Science, Experience, and Species Management
The ESA requires that listing decisions be made solely on the basis of science. Much has been
written about this role of science, its complexities, legal interpretations regarding how much
scientific evidence is required to sustain a decision, and what constitutes the best‐available
science. Two information challenges merit particular scrutiny as multispecies and ecosystem
management become increasingly relevant. The first is a straightforward—though complex—
scientific constraint. The second involves the relationship between scientific and experiential
knowledge.
SCIENTIFIC CHALLENGES
Consider the scientific constraint. The FWS has signaled an intention increasingly to use a
multispecies and ecosystem‐based approach to ESA decisionmaking. Yet the science to support
such decisionmaking is not well developed and involves substantial uncertainties. Landscape
ecology is developing approaches to multispecies management. However, as one recent study
concluded, its “treatment of uncertainty is in its infancy” (Burgman et al. 2005). Some scientists
have proposed what they refer to as a “focal‐species approach (Lambeck 1997);” others use an
“umbrella species concept (Roberge et al. 2004).” Both involve targeting a single species or set of
species and developing management options intended to restore vegetation and improve
ecosystem processes that benefit these species. These approaches assume that the survival
requirements of these targeted species—either clusters of species or individual indicator
species—encompass the ecosystem attributes necessary to meet the needs of other biota in the
same ecosystem.
Critics note that managers lack data “to guide the selection of a set of focal species in the majority
of landscapes” (Lindenmayer et al. 2002). Moreover, they note the limited success of such
strategies, especially those that use a single species as a surrogate for landscape health. One
study of attempts to apply the umbrella species concept, for example, concluded that:
“[U]mbrella species from a given higher taxon may not necessarily confer protection to
assemblages from other taxa.” At the same time, this study noted that “multi‐species strategies
9 SCARLETT | RESOURCES FOR THE FUTUREbased on systematic selection procedures . . . offer more compelling evidence of the usefulness of
the concept” (Roberge and Angelstam 2004). But this conclusion is contested by others who find
that “the utility of umbrella and flagship species as surrogates for regional biodiversity may be
limited” (Andelman and Fagan 2000).
The management of the endangered northern spotted owl is instructive (Courtney et al. 2004).
Protecting a network of so‐called “late‐successional reserves” was intended to conserve late‐
successional forest conditions and benefit all associated species, including the northern spotted
owl. This ecosystem‐based approach was designed to achieve multispecies benefits. However,
protection of suitable habitat for the owl (and other species) did not prevent invasion by the
barred owl, a significant competitor and threat to the northern spotted owl. In some respects,
these limitations of a habitat‐focused approach reinforce the relevance of what the ESA has
required since its inception—a multifactor evaluation of threats to species and, when a species is
listed, a multifaceted approach to addressing all the threats, including but not limited to habitat.
The scientific challenges of using an ecosystem‐based approach to species management do not
negate its relevance. In many respects, such an approach is more consistent with the complex,
intersecting natural world. But these challenges do underscore the need both for more scientific
inquiry, the development and evaluation of ecosystem‐based management tools, and the linking
of these tools to other management considerations beyond habitat protection.
EXPERIENTIAL KNOWLEDGE
Another “knowledge” challenge relevant to enhancing implementation of the ESA in an
ecosystem context is incorporating experiential knowledge—the knowledge of situation, place,
and practice—in recovery planning and conservation measures. Such knowledge helps pinpoint
the possible and define the doable.
Consider the effect of fisheries practices on the albatross in Alaska. The FWS had noted a
declining albatross population in the state and concluded that commercial fishing practices were
affecting albatross. The FWS presented the scientific information about albatross to the fishing
community. The community, previously unaware of their impacts on albatross, used their
experiential knowledge to come up with alternative ways to fish that would not adversely affect
the albatross. The combination of scientific and experiential knowledge brought about a
reduction in harm to albatross.
For many years, recovery planning for listed species received less attention than status reviews of
species and corresponding listing decisions. That imbalance is beginning to change, with the FWS
now having completed recovery plans for many listed species. The recovery planning process is
also in transition. Recovery plans have often been the product of teams of scientists and have not
included farmers, ranchers, the fishing community, or other resource managers that have
10 SCARLETT | RESOURCES FOR THE FUTUREpractical, experiential knowledge potentially relevant to identifying sustainable and feasible
actions within recovery plans. Increasingly, the FWS is composing recovery‐planning teams of
scientists, resource managers, and others to introduce many kinds of information and knowledge
into the planning process.
Conclusion: Managing Species Holistically
The challenges of interdependence, interconnections, and complexities put a premium on
developing tools for cross‐jurisdictional, public–private, and private–private coordination and
cooperation. Collaborative initiatives (for example, the Blackfoot Challenge in Montana, the Duck
Trap River collaboration in Maine, the Puget Sound Partnership, and others) are building blocks
for this coordination and cooperation.
Growing attempts to look more holistically at species management and ecosystem protection also
offer better prospects for avoiding unintended consequences of management actions and taking
actions at a scale more commensurate with the problems that at‐risk species face. Indeed, we
need these evolving approaches if we are to increase our chances of recovering many species in
the face of water scarcities and heightened competition for water, land fragmentation, and the
effects of a changing climate.
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